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The record contains no evidence of the aggregate fair market
value, at decedent's death, of the family farm land securing the
Land Bank loan that was not included in decedent's estate.
Miscellaneous Facts Relating to Land Bank Loan
The deeds by which decedent gave her interest in the family
farm land to the children during 1979-93 provided that the gifts
were made subject to the Land Bank debt and that the debt was
expressly assumed by the grantees.
No claims were filed against decedent's estate by the Land
Bank or by any of the signatories of the promissory note
representing the Land Bank loan.
Payments of principal and interest have continued to be made
on the Land Bank loan since decedent's death. As of March 1,
1998, the balance of the Land Bank loan had been reduced to
$636,814 from the $825,068 balance at decedent's death.
Petitioner admits that, if decedent had made more than her
proportionate share of the Land Bank loan payments, she would
have been entitled to contribution from the other signatories of
the promissory note under Indiana law.
OPINION
I. Did Decedent Make Taxable Gifts of Investment Income
Received by Garry's Estate During 1979-93?
In the statutory notice, respondent determined that
decedent, as a beneficiary of Garry's estate, became entitled to
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